Fintech 2025

ARGENTINA Law and Practice Contributed by: Santiago J. Mora, Nicolas Garfunkel, Milagros Caneda and May Steward, GPG Advisory Partners

and fiat currencies; (ii) exchange between one or more forms of virtual assets (…).” However, despite providing greater clarity to the crypto landscape with the enactment of this law and the regulations issued by the CNV and the UIF, crypto-asset exchange platforms them - selves are still not fully regulated. In this regard, the CNV has submitted to public consultation a rule with a greater number of obligations on PSAVs, which has not been definitively issued yet. 6.4 Listing Standards In Argentina, a standard for listing AVs has not yet been established. Within the context of equity crowdfunding men - tioned in 6.1 Permissible Trading Platforms , equity crowdfunding platforms must review and select the projects that will be offered for financ - ing. For this purpose, a project selection guide must be prepared that must include objective, reasonable and non-discriminatory parameters applying measurable and consistent criteria. In addition, the platform must contemplate proce - dures to inhibit or cancel potentially fraudulent projects. 6.5 Order Handling Rules CNV rules set down the guidelines on how agents must execute orders placed by investors. In this respect, it is established that orders must be executed in the terms given by the clients and promptly entered into the order registration sys - tem of the market. Furthermore, the agents are required to have procedures in place that allow them to enter orders into the computer trading system of the interconnected market where the best market conditions are available to their cli - ents, while the system used by the agent for the

placement of orders must ensure the accurate registration of the order in the transaction ticket. In addition, the CNV has specific rules for equity crowdfunding (see 6.1 Permissible Trading Plat- forms ). 6.6 Rise of Peer-to-Peer Trading Platforms The rise of peer-to-peer (P2P) trading platforms significantly impacts both traditional financial institutions and fintech players. By reducing or entirely eliminating the role of intermediaries, these platforms lower commissions and make services more affordable. This creates compe - tition for traditional banks and fintech compa - nies offering digital exchange services, as P2P platforms operate with lower costs by avoiding traditional infrastructure. A key challenge lies in the regulatory frame - work. In Argentina, P2P trading platforms are not specifically regulated, which poses risks for investors who have less protection due to the absence of a defined legal framework. 6.7 Rules of Payment for Order Flow In Argentina, the practice of payment for order flow is not well regarded as this could affect mar - ket transparency and would be contrary to the duty of loyalty and diligence owed to investors. In this regard, see 6.8. Market Integrity Princi- ples . 6.8 Market Integrity Principles The CML recognises the following principles: • investors’ protection and the prevention of abuses; • the need for small and mid-cap companies to have access to the capital markets;

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